Kenya Publishes Draft APA and Minimum Top-up Tax Regulations

The Kenya Revenue Authority has issued a public notice on draft regulations for the implementation of advance pricing agreements (APAs) and the Pillar 2 minimum top-up tax. New measures for APAs were approved as part of the Finance Act 2025, while new measures for top-up tax were approved as part of the Tax Laws (Amendment) Act 2024 and clarified as part of the Finance Act 2025. The APA regulations have no particular effective date, while the top-up tax regulations will apply from 1 January …